Mining for insights from transfer pricing leaders

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement


Mining for insights from transfer pricing leaders

Taxpayers should not pass the opportunity to get answers from influential transfer pricing officials in September.

The importance of transfer pricing as a reputational issue means it is critical that taxpayers have the right policies to enable them to comply with their obligations on the topic around the world.

Businesses need to understand national rules on related-party transactions, develop the best ways - including having the right technology - to adhere to them and maintain an awareness of how the rules might be changed or added to in the future.

Their knowledge and understanding of national transfer pricing laws and rulings in a given jurisdiction allows tax departments to make the right decisions on subjects, such as the financing of a subsidiary, the location of an R&D project, the suitability of an advance pricing agreement, the correct methodology when documenting a transaction or the approach to take when faced with an audit, as well as monitor tax risk.

Australia, Canada and the UK are three jurisdictions that have proposed amendments or gone ahead with rewrites to their transfer pricing regimes in the last few months. Advance pricing agreements are now possible in Hong Kong and India - though no guidance has been published in that country yet. And concepts such as management fees and location savings are getting wider exposure around the world.

These are important developments that require careful thought and analysis, particularly at a time when transfer pricing rules and regulations are developing rapidly all over the world, judges are getting the opportunity to interpret existing laws, sometimes in unforeseen ways, and tax administration is becoming more and more international, with ideas and tips being passed back and forth by revenue authorities all the time.

The Ask the Authorities panel at September’s Global Transfer Pricing Forum, hosted by International Tax Review and TPWeek, offers executives a unique platform to get answers to their questions about related-party matters.

Officials from three countries will field queries about all aspects of transfer pricing during the 75-minute discussion at 1.30pm on September 25. The agenda covers documentation, legal certainty, advance pricing agreements, joint audits and alternative dispute resolution, though the participation of Michelle Levac, of the Canada Revenue Agency, who chairs the OECD’s Working Party No 6, makes it likely that the multilateral organisation’s most recent projects on intangibles and restructuring will also come up.

The other panellists are Eric Lesprit, the head of the APA team at the French Tax Administration and Peter Steeds, who took over as head of transfer pricing at HM Revenue & Customs in the UK last October.

more across site & shared bottom lb ros

More from across our site

India's tax authorities are increasingly scrutinising the rationale behind cross-border structures
Sharmila Sanmugam's move from industry to WTS UK offers an early glimpse into how the fledgling firm hopes to compete with larger rivals
Historical claims involving KPMG Australia's tax practice have surfaced as the firm battles a separate parliamentary inquiry into its handling of whistleblowers
While AI is revolutionising tax work, it is also reshaping clients’ willingness to pay for advice and their perception of the value generated by tax advisers
From Dhruva Advisors to Svalner Atlas, Ryan is growing fast. Tom Shave discusses consolidation, competition, and tax’s private equity debate
Awards
ITR is delighted to reveal the shortlisted nominees for the Middle East Tax Awards
The UK has confirmed its approach to the OECD’s side-by-side deal, but US-parented groups may find pillar two compliance remains far from straightforward
Fragmented pillar two taxation and increased use of AI by tax authorities have left clients fearful of heightened disputes exposure
Grant Thornton Advisors’ latest acquisition has produced the fifth-largest US advisory firm by revenue, but there’s still a clear gulf between it and the big four
Crowe joins Grant Thornton, WTS and Ryan in attracting PE investment, suggesting that dealmakers remain bullish on the tax advisory sector
Gift this article